Bankers' pay has become one of the most divisive issues among G20 members as they prepare for September's summits on the world's financial system.

UK Chancellor Alistair Darling earlier this month pledged to put bankers' pay on the agenda of the finance ministers meeting in London on September 4, claiming an international approach was needed to crack down on excessive pay in the financial sector. But it would appear European leaders may not be reading from the same script, with some pressing for tougher reforms.

Even before Tuesday's deal with banks, the French government was saying the UK's code on remuneration published earlier this month didn't go far enough and wasn't appropriate as a global agreement. In particular, it objected to the UK's Financial Services Authority decision to use guidelines, rather than specific rules, to shape banks' pay practices.

"The problem with guidelines is that you apply them when it suits you," a spokesman for France's finance minister, Christine Lagarde, said on Tuesday. He added that there were very strong lobbying movements in the US and the UK that had the potential to derail reform on pay. "We want to make sure everyone is playing by the rules, because if not, there is no point in having the rules," he said.

Germany has mostly agreed with France at G20 meetings, although according to a spokesman for the German government, German Chancellor Angela Merkel hasn't yet formed a clear position on pay rules for the Pittsburgh summit, which officially starts September 24. Merkel has to balance her position for the main G20 summit in Pittsburgh with the general election that follows soon after on September 27.

But Merkel has allied herself with French President Nicolas Sarkozy before. Prior to the London summit, she held a joint press conference with Sarkozy urging the G20 to place more emphasis on financial regulation than stimulus spending. Sarkozy said at the time that Germany and France "will speak with one and the same voice." Asked if Germany could again unite with France at September's summit, a spokesman for the German government said: "Yes, I think so."

European leaders might get a chance to iron out their differences at a meeting in Stockholm proposed by Swedish Prime Minister Fredrik Reinfeldt in July in his capacity as the holder of the European Union presidency. Sarkozy has expressed support for the idea, while a spokesman for the German government said he expected it to go ahead, although Reinfeldt said on Tuesday it isn't certain the meeting will take place.

G20 members seem to agree that pay should have extra limitation at companies that have received state aid. The US had restrictions in place on the pay practices of banks that received money through the Troubled Asset Relief Program, though a number of banks, including JP Morgan and Goldman Sachs, have repaid the money and are no longer subject to them.

In Russia, Finance Minister Alexey Kudrin has urged executives of banks and state-run companies to reduce bonus payments for the duration of the crisis. Representatives of Russian ministry of finance didn't return calls for comment ahead of the G20 summit.

In Australia, a row over pay caps meant that the government's proposed commercial-property bailout fund was voted down in the senate. In June, the A$4bn (€3.3bn) fund was aborted after Australian Prime Minister Kevin Rudd's government refused demands to put a A$1m cap on the salary of banking and property executives whose companies would have benefited from the project.

"Executive remuneration is clearly an important issue in terms of financial sector reform and we look forward to ongoing constructive discussions on this matter," said a spokesman for Australian Treasurer Wayne Swann.

In Canada, a spokesman for the department of finance only said that the country "supports the statement from the G20 leaders' summit in London last April." The G20 countries agreed to pursue the compensation principles established by the Financial Stability Board. Those principles called for more effective oversight of a financial institution's compensation practices by board of directors, a better alignment of compensation with risk, and clear disclosure of compensation practices to stakeholders, among other items.

A spokesman for Italian market regulator Consob said that neither the body nor the Italian Government had outlined a position on the oversight of bank pay. However, the spokesman said Consob may be willing to intervene in the future to regulate the matter.

Write to Matt Turner at mturner@efinancialnews.com; Liam Vaughan at lvaughan@efinancialnews.com and Cardiff De Alejo Garcia at cgarcia@efinancialnews.com